INTERTANKO Process • Reviews within ISTEC and Bunker sub-committee over many years – with new emphasis since 2005 • Ongoing contacts with other stakeholders • Reviewed with Executive Committee (June 2006) - basis emphasis on IMO Intersessional meeting in November - Decision that INTERTANKO should contribute actively to the revision process - Secretariat to develop a position paper for submission to IMO, in conjunction with ISTEC for technical and operational evaluation • Reviewed draft submission with Executive Committee (September 2006) - Decision to support submission to Intersessional • Informal discussion with RT since mid-year • Joint reviews with INTERCARGO’s CASTEC • Invitation to RT to co-sponsor submission immediately after agreed by Executive Committee

Guiding Principles Executive Committee (June 2006) – Approach to revision process – prevent fragmented regulations – promote establishment of a global standard for at sea, coastal and at berth operations (maybe no SECAs) – international standards via IMO – regulations based on a fuel standard rather than an emissions performance standard, and thus reduce the onus of responsibility on the owner/operator for verification and compliance (sympathy for use of clean fuels / distillates only)

Guiding Principles Executive Committee (June 2006) – Principles for an INTERTANKO position: – ensure a solid platform of requirements – be realistic and feasible – seek a long term and positive reduction of air emissions from ships, and – contribute to a long term and a predictable regulatory regime

INTERTANKO Approach TABLING FOR DISCUSSION: • The use of distillate fuels, with a global S content cap introduced using a two tiered programme, as follows: – from [2010], a maximum of 1. 00% S content – for ships’ engines installed on and after [2015], a maximum [0. 50]% Sulphur content • A Global Sulphur Emission Control Area • If the above two issues were considered feasible, then the provisions for checking and monitoring compliance with Regulation 14 and 18 should be revised accordingly.

Objective of INTERTANKO submission • The main purpose of the INTERTANKO submission is to "present issues that merit further discussion by the IMO Working Group when considering the revision of Annex VI of MARPOL" • INTERTANKO believes that it is important that there is open debate at the international level on the subject of how best to meet rapidly changing expectations for lower ship emissions and that there should be full and frank discussion of the various solutions possible.

DISTILLATES - ADVANTAGES • eliminates the need for scrubbers for the inert gas system • no additional costs of installing, operating and, maintaining/repairing equipment for reducing PM and SOx emissions • no potential losses due to delay in case of unexpected breakdown of onboard technology • if no SECAs, no operational burdens for ships & no associated risks when changing fuel types, lube oils and settings for the ship’s engines

ONE Approach for CALIFORNIA Environmental achievements 2006 • Maersk Line announced a pilot environmental initiative that annually reduces vessel-related emissions from the company’s fleet that calls the ports of Los Angeles and Oakland, USA. Maersk Line has voluntarily switched to low-sulphur diesel on the main and auxiliary engines of its vessels when they are within 24 miles of the port and alongside. Maersk Line projects a 73% annual reduction in particulate matter and a 92% reduction in sulphur dioxide (SOx).

Further information

Regulation 14 - SOx • The Worldwide Sulphur cap on fuel oil is set at 4. 5%. • Sulphur Emission Control areas (SECAs) – Areas – Baltic, North Sea and English Channel – Sulphur Level of fuel – 1. 5% or; – Alternatively use an exhaust gas cleaning system – Ship must have cleared all pipe systems and tanks and be using low sulphur fuel on entry

Regulation 13 – NOx • For all Engines (except emergency engines) installed on ships after 1 st January 2000 of more than 130 k. W must comply to this Regulation. • The NOx emission is limited to 17 g/k. W h for engines operating at 130 rpm but reducing to 9. 8 g/k. W h for 2000 rpm. Between these revs the limit is designated by equation: 45 * n(-0. 2) g/k. W h • Existing engines can become a “new” engine if substantially modified.

Particulate Matter Regulation and Control Methods • At present this subject matter has not been fully debated within the working group • Issues to be confronted: – Size of the Particulate to be regulated – 10 micron or 2. 5 micron – Extent of limitation of Particulate emission – Methods for control of Particulate emissions – e. g. Scrubbers and/or Filters – Storage and Disposal of Particulates – Control and verification of reduced emissions

Current Regulation 18 – Fuel Oil Quality • “Fuel oil shall be blends of hydrocarbons derived from petroleum refining” • “Fuel oil shall be free from inorganic acid” • “Fuel oil shall not include any added substance or chemical waste which either: – Jeopardises the safety of ships or adversely affects the performance of the machinery, or – Is harmful to personnel, or – Contributes overall to additional air pollution”

Regulation 18 – Fuel Oil Quality • Bunker Delivery Note (BDN) – Becomes a Statutory document – Must be kept on board for 3 years for inspection and a copy taken for further examination. – Must contain all data required by appendix V • • • Name and IMO number of vessel Port Date of Commencement of delivery Details of fuel oil supplier Product name, quantity , Density at 15 0 C and Sulphur content % m/m • A declaration that fuel supplied meets Regulation 14 and 18.

Regulation 18 – Fuel Oil Quality • Fuel Oil Sampling • A sealed sample meeting the requirements in associated guidelines has to given to the ship by the bunker supplier • For each individual BDN a sample has to be taken at the vessel’s bunker receiving manifold. (see procedure in associated guidelines) • The sample label has to be signed by both the bunker supplier’s representative and the vessel’s Chief Engineer. • The sample size shall be not less than 400 mls • The sample is not to be used for any commercial purpose • The sample is to be retained on board for at least 1 year for inspection by PSC as required